Cynthia Hewlett’s son was placed with his maternal grandfather as a temporary guardian after birth, when Hewlett was struggling with mental illness, substance use, homelessness, and incarceration. She later completed a mental-health diversion program, remained drug-free, maintained stable housing and treatment, and visited her son regularly. The grandfather and his wife petitioned to adopt, and the superior court terminated Hewlett’s parental rights. The Court of Appeals reversed. The petitioners had to prove not only parental dependency but also, by clear and convincing evidence, that continued dependency would likely cause the child serious harm. The record did not show that remaining with the grandparents would harm the child through instability or impermanence, or that continuing a relationship with Hewlett would harm him. The grandparents supported visitation and acknowledged the child’s need for his mother. The court emphasized that parental rights cannot be terminated merely because an alternative placement might be preferable. A special concurrence further emphasized the constitutional protection for familial relations. The adoption-based termination order was therefore reversed.